Legal Framework

STAG complies with the applicable legal and regulatory frameworks, with the most relevant being:

• Penal Code (in which Article 368-A defines the crime of money laundering).
• Law no. 97/2017, of August 23 – Regulates the application and enforcement of restrictive measures adopted by the United Nations or the European Union and establishes the sanctioning regime applicable to violations of these measures.
• Law no. 96/2017, of August 23 – Defines the objectives, priorities, and guidelines of criminal policy for the 2017–2019 biennium.
• Law no. 92/2017, of August 22 – Mandates the use of specific means of payment in transactions involving amounts equal to or greater than 3,000 euros.
• Law no. 89/2017, of August 21 – Approves the Legal Framework of the Central Register of the Beneficial Owner.
• Law no. 83/2017, of August 18 – Establishes measures to combat money laundering and terrorist financing.
• Law no. 15/2017, of May 3 – Prohibits the issuance of bearer securities.
• Law no. 72/2015, of July 20 – Defines the objectives, priorities, and guidelines of criminal policy for the 2015–2017 biennium.
• Law no. 52/2003, of August 22 – Establishes measures to combat terrorism.
• Law no. 5/2002, of January 11 – Establishes measures to combat organized and economic-financial crime and provides a special regime for evidence collection, breach of professional secrecy, and asset forfeiture to the State in relation to various crimes, including money laundering and terrorist financing.
• Decree-Law no. 123/2017, of September 25 – Establishes the regime for converting bearer securities into registered securities, in execution of Law no. 15/2017, of May 3.
• Decree-Law no. 61/2007, of March 14 – Approves the legal framework applicable to the control of cash amounts transported by individuals entering or leaving the EU through national territory, as well as to the control of cash movements with other EU Member States.
• Council of Ministers Resolution no. 88/2015, of October 1 – Creates the Coordination Commission for Policies on the Prevention and Combating of Money Laundering and Terrorist Financing.
• Ordinance no. 345-A/2016, of December 30 – Amends Ordinance no. 150/2004, which establishes the list of countries, territories, and regions with privileged tax regimes.
• General Tax Law – Article 63-C imposes the mandatory use of bank accounts exclusively dedicated to business activities, as well as – in the case of invoices or equivalent documents equal to or exceeding 1,000 euros – the use of payment methods that allow the identification of the respective recipient.
• General Regime of Tax Infractions – Article 129 establishes the fines applicable to offenses arising from the violation of obligations set out in Article 63-C of the General Tax Law.
• Notice of the Bank of Portugal no. 8/2016, of September 30 – Regulates the duties of registration and communication to the Bank of Portugal regarding operations corresponding to payment services whose beneficiary is a natural or legal person based in any offshore jurisdiction, as well as the conditions, mechanisms, and procedures necessary for compliance.
• Notice of the Bank of Portugal no. 5/2013, of December 18 – Defines the conditions of operation, mechanisms, and procedures considered appropriate and necessary for conducting monitoring controls to ensure compliance with legal duties for ML/TF prevention.
• Notice of the Bank of Portugal no. 9/2012, of May 17 – Approves the Money Laundering and Terrorist Financing Prevention Report (RPB), establishing its annual completion and submission to the Bank of Portugal via the BPnet system.
• Notice of the Bank of Portugal no. 7/2009, of September 16 – Prohibits the granting of credit to entities based in non-cooperative offshore jurisdictions or whose ultimate beneficiary is unknown.
• Notice of the Bank of Portugal no. 5/2008, of December 18 – Defines the principles and minimum requirements that the internal control system of financial institutions must meet.
• Instruction no. 9/2017, of July 3 – Identifies and establishes the requirements applicable to verification procedures under point (c) of paragraph 5 of Article 18 of the Bank of Portugal Notice no. 5/2013, for compliance with the identification obligation under Article 7 of Law no. 25/2008, of June 5.
• Instruction no. 46/2012, of December 17 – Approves the Self-Assessment Questionnaire (QAA) on ML/TF prevention, establishing its annual completion and submission to the Bank of Portugal via the BPnet system.
• CMVM Regulation no. 3/2015 – Venture Capital, Social Entrepreneurship, and Specialized Alternative Investment.
• CMVM Regulation no. 2/2015 – Collective Investment Undertakings (Securities and Real Estate) and Marketing of Open Pension Funds for Individual Membership.
• Deliberation no. 988/2017, of November 9 – Procedures regarding compliance with the obligation to report commencement of activity and real estate transactions carried out.
• Regulation no. 282/2011, of May 6 – Regulates the duties established in Law no. 25/2008, of June 5.
• Circular Letters from the Bank of Portugal and/or CMVM and/or EU Regulations, which establish restrictive measures against certain persons and entities.
• It is also recommended to consult the online portal www.portalbcft.pt, under the Legislation section, where all up-to-date legislation is available.

Measures for the Prevention and Combat of Money Laundering and Terrorist Financing (AML/CFT) at STAG.

STAG has internal policies and procedures in place to ensure compliance with national legislation regarding AML/CFT.

STAG implements the following relevant policies and procedures:

• Risk Assessment, which determines a fundamental process in how money laundering and terrorist financing should be prevented and combated, establishing a risk-based approach. Following this approach, STAG dedicates greater attention to controls over clients, products, markets, transactions, or counterparties that pose a higher risk of money laundering and terrorist financing.
• Preventive Duties, which impose a diverse set of obligations designed to ensure the prevention of, among other issues, money laundering and terrorist financing. The following general preventive duties are especially noteworthy: Duty of Control, Duty of Identification and Due Diligence, Duty of Reporting, Duty of Abstention, Duty of Refusal, Duty of Recordkeeping, Duty of Examination, Duty of Cooperation, Duty of NonDisclosure, and Duty of Training.
• Customer Due Diligence and Monitoring, which ensures compliance with the obligation to identify clients and uses digital records to monitor operations. All new account openings are screened against lists of suspects and terrorist organizations provided by the competent authorities.
• Politically Exposed Persons (PEPs) and holders of other public offices are identified, and their transactions are subject to enhanced monitoring (both as clients and as beneficial owners).
• Document Retention is ensured for a period of 7 years after the transaction, even if the business relationship has ended.
• Monitoring of Suspicious Transactions is carried out using a risk-based approach.
• Reporting of Suspicious Transactions is performed in accordance with internal policies and procedures to fulfill the legal obligation to report suspicious transactions that may constitute money laundering or terrorist financing to the Attorney General’s Office and the Financial Intelligence Unit of the Judiciary Police.
• The Compliance Function is exercised independently.
• Sanctions Policy: STAG does not establish or maintain business or operational relationships with individuals or entities from sanctioned countries.

Complaints

STAG has a complaints management process, which may be initiated through one of the following means:

a) By letter addressed to STAG:

STAG Fund Management SCR S.A.
Rua Serpa Pinto 14A 1º andar, 1200-445 Lisboa, Portugal

b) By email to: [email protected]

c) By phone: +351 218 530 236

e) In the “Complaints Book” available at the STAG office

Complaints may also be submitted to the following entities:

– To the Bank of Portugal, via the postal address: Banco de Portugal, Apartado 2240, 1106-001 Lisbon or by email using the form available on the Bank of Portugal’s website;

– To the Portuguese Securities Market Commission (CMVM), addressed to the Investor Support Office, via the postal address: Rua Laura Alves, 4, 1064 – 003 Lisbon or through the CMVM website.